"I didn't know where we were…I didn't know if we were hanging off the bridge," Wren said, recalling that Klotz, who suffered a broken femur, was screaming in pain.

Barnes asked Wren if she looked at the other vehicle once she got out of hers, and she replied she could see the driver of the pickup "hunched over," but nothing else, through the truck's back window.

After EMTs placed her in a back brace at the scene, Wren said, she saw a tarp had been draped over the pickup, an indication to her "the people inside were deceased."

Klotz, who was 21 at the time of the accident, also testified Friday, as did Tanya Hess, who witnessed the accident; however, much of the day's testimony was from Robert Miller, an accident reconstructionist who was called as an expert witness for the state.


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'Driver error' conclusion

Miller, who also testified Thursday, took the stand in the middle of the plaintiffs' case because he had a previous obligation to testify in a lengthy trial in Florida next week, Pace said during a recess.

Under direct examination by Pace, Miller explained how he conducted his investigation of the accident and how he compiled a 2006 report in which he concluded the accident was caused "by loss of control by the driver [Mr. Connor]."

Asked by Pace if that meant "driver error" was involved, Miller said yes, explaining that he had concluded Mr. Connor was driving "too fast for conditions" and that there was "failure to maintain control of his vehicle."

The witness also said at several points during both direct and cross examination that he could find no evidence to suggest the condition of the roadway contributed to the accident. Nor, he said, was there any evidence of standing water on the road surface.

Miller also said if there had been a barrier, particularly a concrete Jersey barrier, separating the oncoming lanes of traffic on the four-lane bridge, it would not have prevented an the accident but would have "directed" the Mazda back into the lanes on its side of the barrier, rather than crossing into the lanes of oncoming traffic.

Though Miller conceded the outcome "would have been very different" with a barrier in place, he said that didn't necessarily mean nobody would have died in the Mazda or in another vehicle traveling to the right of the barrier. Based on his research, he said, in many instances a vehicle striking a Jersey barrier will roll over. There is a greater probability of fatality in a rollover collision, he added.

Drawing conclusions

Miller, who is a licensed mechanical engineer, testified he relied on police reports and other official documents from the accident investigation, while also applying "principles of physics," to determine what happened.

He also visited the scene in February 2006, taking measurements of the slope of the roadway, while bridge police directed traffic around him, he said.

Because it was five years after the accident when he began his investigation, Miller said he could only rely on photographs taken by police to examine the condition of the vehicles following the accident. He said there was no way to determine how fast either vehicle had been going before or during impact, nor had police investigations found any tire marks to take skid measurements, explaining they had been washed away by the rain.

Relentlessly attacking Miller's methodology and conclusions under cross examination, Barnes suggested at several points that Miller had either failed to go far enough in his research or had been provided with insufficient or incomplete information by his clients, the state defendants. Miller denied that was the case.

Barnes asked Miller if he had interviewed any of the survivors of the crash or witnesses or any of the police investigators, particularly with regard to how hard it was raining prior to the accident. He said he had not, noting that such information taken so long after the fact is typically unreliable, while "a witness recalls more in a [police] statement."

Miller conceded he did not know with any certainty how hard it was raining or if, in Barnes words, it was "drizzle" or a "torrential downpour."

Weight in the bed

Barnes also questioned the state's expert about the differences between a pickup and a car, eliciting the answer that in a pickup, more weight is "concentrated on the front wheels than on the back."